Multinational

OECD’s Angel Gurría speaks on BEPS in Washington

April 21, 2015

The G20/OECD base erosion profit shifting (BEPS) project is in its "decisive stages," with only six months remaining until the 15 BEPS deliverables must be completed, Angel Gurría Secretary-General of the OECD said at a meeting of World Bank Group and International Monetary Fund officials, G20 Finance Ministers, and Central Bank Governors held . . .

OECD to involve developing nations in BEPS project

November 12, 2014

The OECD will invite some developing nations to participate in OECD Committee on Fiscal Affairs (CFA) meetings, will hold regional consultations, and will work on capacity development in an effort to increase developing nation input in the OECD/G-20 base erosion profit shifting (BEPS) plan decision-making . . .

UPDATE: Philippines Joining OECD Committee on Fiscal Affairs: The Philippines will join the OECD Committee on Fiscal Affairs to work on a global response to BEPS beginning January 2015, the Philippines Department of Finance announced November 14. See, Philippines release.

OECD guidance proposes simplified transfer pricing treatment for low value-adding intra-group services

November 3, 2014

Draft guidance released November 3 would modify the OECD transfer pricing guidelines to provide elective, simplified, transfer pricing rules for low value-adding intra-group services.   The guidance was released in response to Action 10 of the OECD Base Erosion and Profit Shifting (BEPS) plan, which directs the OECD to develop transfer pricing rules or special measures "to provide protection against common types of base eroding . . .

Private tax rulings granted by Luxembourg to Amazon under EU scrutiny

October 7, 2014

The European Commission on Oct. 7 announced that it has opened an in-depth investigation into whether Luxembourg granted private rulings to an Amazon subsidiary with too favorable terms, potentially violating EU rules on state aid. The 2003 tax ruling, which is still in force, sets a methodology for the payment of a tax deductible royalty by Luxembourg-based Amazon EU Sàrl to a related limited liability. . .

Australian official says six nations jointly investigating e-commerce firms; reviews ATO work on BEPS

May 22, 2014

An Australian Taxation Office (ATO) official, on May 22, confirmed that Australia and five other nations are collaborating to investigate the global tax planning of multinationals operating in the e-commerce industry.Mark Konza, ATO Deputy Commissioner, International, said that Australia was "currently involved in a cooperative compliance approach" with five other nations. The collaboration led to the production of an. . .

Irish government to investigate effect of its tax regime on developing nations

April 29, 2014

Responding to calls from the G-20 and civil society groups, the  Irish government, on April 29,  announced that it will undertake a ‘spillover analysis’ to research what effect Ireland’s tax system has on the economies of developing countries.  The Irish government will engage consultants to assist with the evaluation and has launched a public consultation, asking interested parties to make submissions on the topic. See Public Consultation.

BEPS digital economy work still at square one

April 23, 2014

Members of the OECD task force charged with crafting rules to address the tax challenges of the digital economy still disagree on fundamental issues associated with the project. Speaking April 23, Edourad Marcus, co-chair of the task force, said members are still debating whether they should recommended modifications to the corporate income tax through. . .

OECD BEPS Eurasia regional meeting draws tax officials from only six nations

March 10, 2015

Tax officials that attended an OECD Eurasia regional meeting on base erosion and profit shifting (BEPS) welcomed the OECD's effort to involve developing nations in the BEPS project, but said that barriers prevent nations in the region from participating, according to a report released March 10. These barriers were apparent as representatives of only six nations attended the regional meeting, held in Ankara, Turkey, on March 5-6.. . .

OECD publishes MAP statistics of member countries

November 25, 2014

The OECD on November 25 released 2013 statistics on the mutual agreement procedure (MAP) caseload of OECD member counties and partner economies of Argentina, China, Latvia, and South Africa. According to an accompanying OECD . . .

ECJ rules that intragroup services provided by US company to Swedish branch are subject to VAT, hitting global financial firms

September 19, 2014

A European Court of Justice (ECJ) judgment, released Sept. 17, will result in large VAT bills for banks, insurers, and other businesses considered VAT-exempt.  The decision, Skandia America Corp. v. Sweden, concludes that supplies of services from a non-EU company to its EU branch are subject to VAT when the branch belongs to a VAT group. Previously, provision of these services . . .

Update: For UK government's October 14 reaction to Skandia, see HM Revenue and Customs Brief 37 (2014) - VAT grouping rules

ECJ rejects US company’s assertion that Germany’s differing treatment of foreign and domestic dividends violates free movement of capital

September 11, 2014

The European Court of Justice, in Kronos International Inc. released Sept 11, has ruled that a US registered company resident in Germany may assert that German tax rules violate free movement of capital, but the company may not claim freedom of establishment rights. The ECJ went on to reject the company's contention that Germany's tax rules in effect at the time, which permitted a set off for . . .

EU probes whether tax rulings granted to Apple in Ireland, Starbucks in Netherlands, and Fiat in Luxembourg violate state aid

June 11, 2014

The European Commission, on June 11, announced that it is investigating whether individual transfer pricing rulings granted to Apple in Ireland, Starbucks in the Netherlands, and Fiat in Luxembourg sanctioned the allocation of too little profit to activities in those countries, thereby amounting to illegal state aid. The Commission has also initiated an infringement action against Luxembourg in connection with the matter.The decision is part of a wider investigation into whether tax rulings and . . .

-Update: The Luxembourg Finance Ministry, in a June 12 statement, said it would continue to defend against the Commission's charges of illegal state aid, and said it still has doubts about the legality Commission requests for information, see statement.

OECD releases discussion draft on improving analysis of BEPS

April 16, 2015

The OECD on April 16 released a draft report under action 11 of the base erosion and profit shifting (BEPS) plan on improving the availability and analysis of data on BEPS and on monitoring the effectiveness and economic impact of actions taken to address BEPS. The report concludes that lack of data . . .
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